Privacy Policy

Stalex Privacy Policy
Overview – the key information you should be aware of
(A) Who we are: We are Stalex Investments Limited, a company which supports the strategic aims of each of our subsidiary businesses as well as operating an investment business. If you need it, our company number is 10260912 and our registered office is Suite 1, 3rd Floor 11 – 12 St. James’s Square, London, United Kingdom, SW1Y 4LB. Stalex Investments Limited is the controller of your personal information, and is responsible for your personal information. All references in this policy to “Stalex”, “our”, “us” or “we” refer to Stalex Investment Limited. All references in this policy to “our website”, refer to the website owned by Stalex at www.Stalexinvest.com.

(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide so if you have any feedback on this privacy policy, please let us know using our contact details in section 11.
(C) Who this policy applies to: This policy applies to:

  1. Visitors to our website;
  2. People who contact us with enquiries; and
  3. Our suppliers, and employees of our suppliers.
    Depending on our relationship, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.

(D) What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

  1. How we obtain your personal information;
  2. Collection of your personal information and how we use it:
  3. Our legal basis for using your personal information;
  4. How and why we share your personal information with others;
  5. How long we store your personal information;
  6. Your rights;
  7. Risks and how we keep your personal information secure;
  8. Links to other websites;
  9. Changes to this privacy policy; and
  10. Further questions and how to make a complaint.

(E) Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6. One of the most fundamental rights to be aware of is that you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.
You can find out more information in section 6.

(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

  1. How we obtain your personal information
    1.1 You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as our suppliers, contractors and consultants, group companies, public websites and public agencies, which we refer to as “third party sources” throughout this policy.
    1.2 You may give us personal information about yourself by using the online functionality provided on our website or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.
  2. Collection of your personal information and how we use it
    Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as “personal information” throughout this policy.

2.1 Visitors to our website
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) information provided when you correspond with us;
(ii) any updates to information provided to us;
(iii) personal information we collect about you or that we obtain from our third party sources;
(iv) the following information created and recorded automatically when you visit our website:
(A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages;
(B) Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads; and
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to allow you to access or use our website;
(ii) to receive enquiries from you through the website about our business;
(iii) for improvement and maintenance of our website and to provide technical support for our website;
(iv) to ensure the security of our website;
(v) to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and
(vi) to evaluate your visit to the website and prepare reports or compile statistics to understand how our website is used. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
(c) A word about cookies
(i) Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
(ii) Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.
(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.

2.2 People who contact us with enquiries
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us; and
(vi) any updates to information provided to us.
(b) How we use your personal information
We will collect, use and store the personal information listed above to deal with any enquiries or issues you have, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests to do so.
Please see sections 2.4 and 2.5 for more details about how we use your personal information.

2.3 Our suppliers, and employees of our suppliers
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) work contact information (phone number, postal address, mailing address, email address);
(iii) your job title;
(iv) information provided when you correspond with us;
(v) any updates to information provided to us;
(vi) personal information we collect about you from third party sources such as companies house:
(vii) CVs, pitch and tender information;
(viii) proof of identification and address;
(ix) visa or work permit documentation;
(x) details of compensation, expense claims and bank details;
(xi) work hours (overtime and hours worked);
(xii) if you attend our sites, CCTV recordings, car registration and the times you arrived at, and departed from, our sites;
(xiii) VAT registration number; and
(xiv) Insurance certificates.
(b) How we use your personal information
We, or third parties on our behalf, will collect, use and store the personal information listed above for the following reasons:
(i) to enable us to purchase and receive products and services from you (including supplier due diligence, payment and expense reporting and financial audits);
(ii) to deal with enquiries from you;
(iii) to confirm information on CVs and performance reference checks, to assess you or your employer’s suitability to work for us; and
(iv) for CCTV monitoring and other security of company facilities.
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third party sources, such as your employer or your employer’s company website. We may also collect this personal information from publicly-available sources, such as LinkedIn.
(d) Information we need. Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer ask us to delete it, you may no longer be able to provide services to us.

2.4 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for business purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.5 Further processing
Before using your personal information for any purposes which fall outside those set out in this section 2, we will undertake a process to establish if our new use of your personal information is compatible with the purposes set out in this section 2. Please contact us using the details in section 11 if you want further information on the analysis we will undertake.

  1. Legal basis for use of your personal information
    3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
    (a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to receive services from you or your employer); or
    (b) our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
    (c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
    (i) run and develop our business and group companies;
    (ii) select appropriately skilled and qualified suppliers;
    (iii) ensure a safe environment for our private tenants and suppliers;
    (iv) place, track and ensure fulfilment of orders with our suppliers; and
    (v) for internal group administrative purposes.
    If we rely on our (or another person’s) legitimate interests for using your personal information, we will check that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this assessment by using the contact details at section 11.
  2. How and why we share your personal information with others
    4.1 Most of Stalex’s processes, procedures and systems are shared across Stalex group companies, which means that we need to share your personal information between us when using it in the ways described above (in the relevant section titled “How do we use your personal information?”).
    4.2 We may share your personal information with other Stalex group:
    (a) where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance); and
    (b) where certain group companies provide services to others (such as IT systems, office services and data storage).
    4.3 We will share your personal information with the following third parties or categories of third parties:
    (a) other service providers and sub-contractors that provide services to us, including payment processors, banks, utility providers, suppliers of technical and support services, insurers, logistic providers, auditors, lawyers, IT contractors and cloud service providers;
    (b) public agencies and the emergency services; and
    (c) HMRC as required to file mandatory returns, for example under the Construction Industry Scheme.
    4.4 Any third parties with whom we share your personal information are limited (by law) in their ability to use your personal information.
    4.5 We will also disclose your personal information to third parties:
    (a) where it is in our legitimate interests to do so to run, grow and develop our business, such as:
    (i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
    (ii) if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
    (b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
    (c) in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
    (d) to protect the rights, property, or safety of Stalex, our staff, our tenants or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
  3. How long we store your personal information
    We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. If you would like further information about the data retention periods we apply to your personal information please contact us via email at enquiries@Stalexgroup.com.
  4. Your rights
    6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at enquiries@Stalexinvest.com at any time. You have the following rights:
    (a) Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; and details about how and why it is being used.
    (b) Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
    (c) Right delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 11.
    We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 11.
    (d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 11.
    We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 11.
    (e) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
    6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
    6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
  5. Risks and how we keep your personal information secure
    7.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
    7.2 For this reason, Stalex is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
    7.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
  6. Transfers outside of the European Economic Area (EEA)
    8.1 We share your personal data within the Stalex Group. This will involve transferring your data outside the EEA.
    8.2 We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    8.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
  7. Links to other websites
    Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
  8. Changes to our privacy policy
    We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
  9. Further questions and how to make a complaint
    11.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact enquiries@Stalexinvest.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
    11.2 You may also make a complaint to the Information Commissioner’s Office. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
    The practices described in this privacy policy statement are current as of 1st March 2020.